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Medical changes to CAA PPL.

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Old 15th Aug 2008, 07:29
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Medical changes to CAA PPL.

CAA Official Record Series 4 No. 689 announces changes to the medical requirement to some PPLs.
Seems that a GP declaration (as per the NPPL) will do for the old CAA (non JAR) PPL.

What the publication fails to mention is if any restrictions apply as they do to the NPPL SSEA rating. Can one now fly abroad on this arrangement?

Also, the exemption expires on 30th June 2009. If this exemption is not renewed in a timely manner (as it wasnt in the saga over the microlight exemption of some years ago) it could be that pilots may not be legal at the end of June 2009 if they chose to go down this route.
Why put a limit to this exemption that really requires the general public to check that the CAA have extended it so that we all stay legal?

I'm getting to the point with all these changes that one day I'll find myself illegal purely that I didnt understand or know about of all these changes.
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Old 15th Aug 2008, 08:27
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Can one now fly abroad on this arrangement?
Only if they file a difference to ICAO on this, which is IMHO unlikely given that EASA is "going to" terminate national licenses from 2012 or so.

Whether anybody abroad will notice, I have no idea. But I wouldn't like to argue this with an insurer - the one thing they do is check whether the flight was legal before it got off the ground.

The more interesting Q is why they are doing this. Is this some kind of "EASA pre-emptive" action? It certainly looks like it; it will make the EASA LPL (with a GP medical) look more or less the same as the old CAA (non-JAA) PPL (also with a GP medical), opening the path for various options... which could be interesting since the EASA LPL is a complicated animal whereas the old CAA PPL is a bit of paper which lasts for life.
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Old 15th Aug 2008, 08:27
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SF I would agree with your last paragraph entirely. It's not only medicals but licences, maintenance and rules of the air which are in a constant state of flux. How could anyone (except a lawyer) justify the old saying, 'ignorance of the law' is no excuse. It doesn't matter who you talk to, including the CAA, they all have different interpretations of what the regulations are. What happened to the good old British common-sense?
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Old 15th Aug 2008, 15:48
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Also, the exemption expires on 30th June 2009.
That's how the CAA usually do this sort of thing. The idea is that it gives them 12 months to change the ANO which requires parliamentary time.
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Old 16th Aug 2008, 09:29
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What good are medicals anyway?

Airline captains who have first class medicals have been known to collapse at the wheel - I think there was a case not too long ago where 1st officer had to complete the flight solo. There can't be any medical that can accurately predict your future health so why not just a simple test of eye-sight from Specsavers, hearing test, blood pressure all the things your GP could do?

What are the statistics?

Me being controversial....
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Old 16th Aug 2008, 10:11
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...it will make the EASA LPL (with a GP medical) look more or less the same as the old CAA (non-JAA) PPL (also with a GP medical), opening the path for various options... which could be interesting since the EASA LPL is a complicated animal whereas the old CAA PPL is a bit of paper which lasts for life.

Interesting. So is this the answer to whether or not we need to sort out a JAR-PPL 'upgrade' for our old lifetime CAA-PPLs?
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Old 16th Aug 2008, 10:31
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So is this the answer to whether or not we need to sort out a JAR-PPL 'upgrade' for our old lifetime CAA-PPLs?
I would not do this unless you have a pressing reason to e.g. you want to go to some JAA State, which does not accept the CAA PPL, and rent stuff there.

The counter argument is that it may cost you less to do the swap now than say next year, but the difference is not likely to be significant on the scale of flying costs - even if a checkride is required. If EASA terminated national PPLs in some crude manner, a lot of **** would hit the fan, and of course they cannot do anything to the French.

In this business, people who took drastic action in fear of something happening usually got shafted. For example, those who got scared of the 2005 DfT proposal to end N-reg long term parking and spent £thousands to go back on G-reg were soon p*ssed off because they wasted their money, as well as depriving themselves of IFR privileges of their FAA IRs.
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Old 16th Aug 2008, 10:51
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What the publication fails to mention is if any restrictions apply as they do to the NPPL SSEA rating. Can one now fly abroad on this arrangement?
I am currently awaiting an updated version of the General Exemption from the responsible person at the CAA. This is because the CAA needs to clarify (internally) whether a SSEA Class Rating will have to be included in a non-NPPL for those who use the General Exemption. If they decide that a SSEA Class Rating will be required, the aim is to make it a free issue.

If you use a Medical Declaration with a non-NPPL + SEP Class Rating, you are restricted exactly as a NPPL SSEA holder is.

MTOW 2000 kg
No more than 4 PoB including the pilot
No night
No IMC
No FI Rating

Use outside UK airspace subject to agreement of the other nation. The French have already said "NON!!".

To my mind, the LPL is an utter crock. It brings nothing new, it doesn't allow Microlight pilots to upgrade as the NPPL does and it combines the worst of all options - a rolling 2 year validity period within a 5 year issue period - work that one out!

The EASA PPL proposals have their own flaws, but the LPL is utter poo - read the MDM032 proposals and you'll see what I mean. I propose that all sub-ICAO licences should be down to individual Member States to sort out and administrate; the minimum €urolicence should be the PPL.
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Old 16th Aug 2008, 19:04
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Thanks BEagle
If you use a Medical Declaration with a non-NPPL + SEP Class Rating, you are restricted exactly as a NPPL SSEA holder is.
Any reference to this under the new medical requirements would be appreciated.
I'm aware of the NPPL restrictions but would like to see where these are quoted legally to apply for this new arrangement.
SF
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Old 26th Aug 2008, 08:32
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To keep you all up to date, I reviewed the latest draft revision to the General Exemption last Saturday and it will make it abundantly clear that anyone using a Medical Declaration with a valid SEP Class Rating will be restricted to the same privileges as a NPPL holder.
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Old 26th Aug 2008, 21:52
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BEagle...
Do you know whether someone using this arrangement would be regarded as operating on a "Sub ICAO" licence"?
The actual Licence operated on will be a PPL (or higher) issued by the CAA and therefore surely an ICAO licence...
If so could it be used to fly an N Reg, in the UK?
Any help or advice appreciated!
UV
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Old 5th Sep 2008, 08:04
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See LASORS A19.

In addition, before acting as pilot-in-command of a foreign
registered aircraft, the licensing requirements of the state
of registration must be met in accordance with ANO
Article 26(3). For ‘N’ registered aircraft, U.S. Federal Air
Regulations (FARs) 61.3(a)(1) states that ‘when the aircraft
is operated within a foreign country a current pilot licence
issued by that country in which the aircraft is operated
may be used’.
However, the grey area is that a Medical Declaration does not meet the normal standards required by the state of registration (USA) for private flight. So I recommend that you don't attempt to fly a N-reg aeroplane without holding a JAA Class 2 medical until this matter is clarified by the Authority.

UPDATE Advice from a chap at the CAA is that, unless the pilot concerned could provide evidence in the form of a letter, signed by an authorised officer of the FAA, that the FAA would find a UK issued sub-ICAO licence acceptable for the purpose of flying an N registered SSEA in the UK, the answer would be no, you may not do so.

Expect to see some guidance concerning this in a forthcoming Advice Circular from the CAA.

Last edited by BEagle; 5th Sep 2008 at 16:37.
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Old 9th Sep 2008, 21:48
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ORS4 689 and 711

Please note that the General Exemption pertaining to the use of a Medical Declaration with a CAA-issued non-NPPL, 'ORS 4 No 689' has now been superseded by 'ORS 4 No 711' - see http://www.caa.co.uk/docs/33/ORS4_711.pdf .

This now spells out quite clearly what the restrictions are; later an Advice Circular will be released by the CAA to spell out further the effects to those who are still in any doubt!
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Old 11th Sep 2008, 12:44
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Beagle,

If or when you fail your JAR Class 2 medical and wish to continue to fly, you will be glad of the NPPL (in future for Annex II aircraft) and the future LPL (for Annex I aircraft). Talk to the thousands who have done so already. Also to the many pilots who do not need a JAR PPL and all the clap that goes with it for basic VFR flying.

For generations the world of private flying has been held back by the inherited thinking of pre WW2 days when it was a 'privilege' (in more than one sense) to fly and the authorities granted you the privilege. They also screened out supposed higher risk candidates by means of applying high medical standards because of the investment being made by CAT and Military organisations in training pilots. The screening should be more appropriate and proportionate to risk for lesser mortals than ATPLs or military pilots. Look at the empirical evidence in other fields. It is compelling.

We must break the assumed link (by the former JAA) between JAR PPL and higher licences. A PPL or LPL should be capable of being seen and accepted as an end in their own right. And with the ability to progress training and experience from LPL to PPL to CPl etc with crediting.

You and others need to recognise that we are trying to reduce the barriers to entry / barriers to continuing flying, based on objective and proportionte risk principles. Otherwise the elite breed will die off gradually without successors from the young taking over the mantle of private flying.

From Cologne where we continue the battle......
Good day
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Old 11th Sep 2008, 13:25
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Advice from a chap at the CAA is that, unless the pilot concerned could provide evidence in the form of a letter, signed by an authorised officer of the FAA, that the FAA would find a UK issued sub-ICAO licence acceptable for the purpose of flying an N registered SSEA in the UK, the answer would be no, you may not do so.
This is self evident fact. The FAA and only the FAA can decide what privileges (if any) a particular license confers on the pilot of an N-reg.

FAR 61.3 already covers this but only for ICAO licenses. However, it does not use the word "ICAO" and this is where the ambiguity arises. IMHO, the context of the FARs eliminates this ambiguity, and a non-ICAO license would not meet 61.3 unless the FAA says so.

This is like the other argument which has been done to death already: whether the IMC Rating is good for an N-reg. I have a written reply from the FAA saying it is fine.

But no matter what written reply you get from the FAA, somebody will always stand up and say that anything short of a reply from the FAA Chief Counsel is worthless. I regard this view as ridiculous because it makes any written answer from any official body completely worthless (which is clearly not the case).

David - your point of view is hard to argue with and all VFR-only pilots (which is also a huge industrial lobby around Europe; all those plastic ultralights etc) will love this. However, it brings a risk that it will sideline the whole "private IFR" scene into a commercial-only route, and that is a BAD thing because IFR delivers a huge increment in mission capability specifically, and in the overall value / return one gets from flying generally.

We already have a situation in which the vast majority of new pilots chuck flying in very soon after getting their PPL. Look at some of the reasons why there is this ludicrous attrition rate.

As for the GP medical, everybody would welcome this. All data shows clearly that pilot incapacitation barely features in the accident stats, and most of the things checked in the Class 1 or 2 medicals (I hold both CAA and FAA Class 1s) are utterly irrelevant to sudden pilot incapacitation anyway. The key thing is that this is equally true for VFR and IFR so delivering a PPL which has a GP medical while stripping out any IFR route is worthless to many pilots.
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Old 11th Sep 2008, 19:39
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David Roberts, I know all about the NPPL, thank you very much, as I am the chairman of the NPPL Policy and Steering Committee. I also reviewed and proposed amendments to ORS 4 No 711 - a very reasonable and generous CAA dispensation, to my mind.

The LPL is an utter crock which should be strangled at birth. MDM032 have rolled over to the French and propose an appallingly weak licence - the NPPL is far superior having been the result of industry and CAA synergy.

All MDM032 proposals should be deleted from the EASA part-FCL proposals forthwith; however, with some minor tweaking, the EAS part-FCL PPL will be fine.

As for medical standards, the eyesight requirements for night and/or IMC work are beyond the remit of GPs, so the AME-adminstered part-Medical Class 2 must remain the minimum standard.
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Old 11th Sep 2008, 20:56
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It still somehow seems wrong to hide behind a handle if one is an official, rather than an ordinary PPL.

Quite apart from that - it may be beyond the remit of a GP, but not beyond the remit of an optician. If one person can sign a form, so could two. Not that I'm personally interested in night or IMC on my NPPL.

Bernard Newnham
retired Senior Producer, BBC TV
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Old 11th Sep 2008, 22:24
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As for medical standards, the eyesight requirements for night and/or IMC work are beyond the remit of GPs, so the AME-adminstered part-Medical Class 2 must remain the minimum standard.
Does that mean that if

(1) I am currently "temporarily" medically unfit for a class 2
(2) I have a GP declaration
(3) I can thus fly with NPPL priviledges on my CAA SEP licence and class rating

that if I were pass the eyesight part of the class 2 medical[#] I might be able to persuade the CAA to let me use my IMC rating via some personal concession (assuming I complete the course and pass the test)?

[#] My AME is always happy with my eyesight, even though I fail the new standards, under grandfather rules (so I get a "NJC" rubber stamp) - with my glasses on I can see better than some of the people he has to pass under the new rules!
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Old 12th Sep 2008, 05:18
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Does that mean that if

(1) I am currently "temporarily" medically unfit for a class 2
(2) I have a GP declaration
(3) I can thus fly with NPPL privileges on my CAA SEP licence and class rating
Yes. But you will not be permitted to use any other privileges until you regain a JAA Class 2 medical. As the forthcoming advice circular will make clear.

And ex-BBC person, if someone patronisingly writes:

You and others need to recognise that we are trying to reduce the barriers to entry / barriers to continuing flying, based on objective and proportionte risk principles.
then I don't feel it is necessary to conceal my many years of voluntary, unpaid work spent getting the NPPL 'airborne'.

We simply DO NOT NEED a sub-ICAO 'EU' LPL (or rather, to roll over to the demands of the French). EU Member States who wish to do so should be permitted to make their own arrangements for sub-ICAO pilot licences in their own airspace - and the MDM032 recommendations should be binned in their entirity. If the French want to go on killing themselves with their ridiculous 'Brevet de Basse', then they should be permitted to do so - but only in French airspace!
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Old 12th Sep 2008, 09:29
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What the revised Exemption still fails to mention is the requirement under Article 28 to hold a valid Certificate of Test or Experience on the class being flown.

A pilot who normally flies SEP is unlikely to have SSEA rating as well, so what is the procedure for obtaining one? Which criteria are to be used for currency in the change over? As the CAA are the only people who can add a rating then charges will surely apply.
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